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a quick question about this statement..

It is also the case that you have no referring URLs, which is typical
of other adnetwork activity such as MetricsDirect/180solutions. That
needs to be disclosed as well as the incentive program itself."

No referring URLs means that the clicks don't show a page or site or whatever to show where they took place. That is typical of other adnetworks. Do you use a third party for your traffic? Though I can have someone figure that out, it's generally easier to just ask.